https://www.taxtmi.com/acts?id=4619 paid cross-border may be taxed by the recipient State; the source State may also tax but, if the recipient is the beneficial owner, source tax is limited to 10 per cent of the gross interest. Exemptions apply for interest paid to the other State's government or central bank; competent authorities may designate other institutions for exemption. The Article defines interest broadly and excludes late-payment penalties. Where the beneficial owner's interest is effectively connected to a permanent establishment or fixed base in the source State, Articles 7 or 15 apply. attributable to a payer's permanent establishment is deemed to arise in the State of that establishment. Special-relationship adjustments limit treaty relief to arm's-length amounts. en-us Sat, 19 Jan 2008 22:45:54 +0530 Mon, 04 Nov 2024 16:39:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=4619 paid cross-border may be taxed by the recipient State; the source State may also tax but, if the recipient is the beneficial owner, source tax is limited to 10 per cent of the gross interest. Exemptions apply for interest paid to the other State's government or central bank; competent authorities may designate other institutions for exemption. The Article defines interest broadly and excludes late-payment penalties. Where the beneficial owner's interest is effectively connected to a permanent establishment or fixed base in the source State, Articles 7 or 15 apply. attributable to a payer's permanent establishment is deemed to arise in the State of that establishment. Special-relationship adjustments limit treaty relief to arm's-length amounts. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=4619